US Tariff Changes in Fall 2026: How Chinese Goods Are Taxed

The US tariff system changed engines in 2026. The IEEPA tariffs were struck down and are being refunded; what replaced them is a Section 301 forced-labor duty plus a much wider Section 232. This article covers what changed in September and October 2026, and how a shipment from China is actually taxed today.

What Changed in September and October 2026

Five developments matter for importers this quarter, and they point the same way: the action has moved to Section 232.

Drones and UAS components (effective 3 September 2026)

Under Proclamation 11055, additional duties now apply to unmanned aircraft systems and components. Drones of 25 kg or less without thermal imaging generally carry 25%; larger drones, thermally equipped models, docking stations and listed critical components carry 100%. Other components join at 25% on 9 February 2027 (91 FR 53699).

Polysilicon and the solar chain (duties from 4 December 2026)

This is the change that reaches solar products: under Proclamation 11052, from 4 December 2026 polysilicon and its derivatives carry an additional 15% duty and minimum import prices — $21 per kilogram of polysilicon, $100 per kilogram for ingots and wafers, and $0.22 per watt for solar cells. To stop a pre-deadline rush, a temporary rule has applied since 22 September 2026: importers are monitored against historical volumes, newly registered importers are capped, and entries are cut off above the thresholds. See 91 FR 60505.

Pharmaceuticals (wider application from 29 September 2026)

Section 232 duties on patented pharmaceuticals and ingredients, generally 100% with lower tiers by country and company, applied from 31 July 2026 to companies named in the annex. From 29 September 2026 they extend to all others.

China Section 301 exclusions (technical, but it releases money)

On 2 September 2026 the USTR amended four China product exclusions to match ten-digit statistical categories that changed on 1 July 2026, and CBP began accepting the amended reporting on 23 September. Entries made between 1 July and 22 September that paid Section 301 duty on those goods can now be corrected through the refund process — worth asking your broker about.

IEEPA refunds (next phase on 6 October 2026)

CBP has been refunding IEEPA duties through its CAPE system since April. A third phase covering entries liquidated for more than 80 days deploys on 6 October 2026, for importers who registered a valid importer-of-record number by 30 July.

The Two Corrections Most Cost Models Still Get Wrong

The IEEPA tariffs no longer exist. The Supreme Court struck down the IEEPA tariff authority in February 2026, the related executive orders were revoked on 20 February, and the Court of International Trade directed CBP to refund what had been collected. The Section 122 surcharge of 10% that briefly replaced it expired on 24 July 2026. Any model still built on a China rate of 20% plus reciprocal tariffs describes a system that has not been in force for most of this year.

Since 24 July 2026, postal shipments pay normal duties too. The last flat-rate treatment for postal consignments ended then, so postal entries are now assessed like commercial ones: normal tariff columns, plus Section 232 and Section 301 where they apply. With the low-value exemption also gone, there is no longer a lightly taxed channel for small commercial shipments.

How a Shipment from China Is Taxed Today

There is no single China rate. What applies is a stack, built line by line from the entry:

• The base rate of the HTSUS line your goods classify under — the starting point, and different for almost every product.
• The China Section 301 list duty — 25% for the earlier lists, 7.5% for the later one, with selected products raised in the 2024 four-year review. The subheading decides this, not the product category name.
• The 12.5% forced-labor duty under 9903.05.31, in force since 24 July 2026, applied to Chinese-origin goods unless a listed exemption covers them. It has no petition route.
• Section 232, where your product is in scope: drones, pharmaceuticals, semiconductors, steel, aluminium, copper, timber and lumber derivatives, and polysilicon from 4 December 2026. Since April 2026 these duties apply to the full customs value rather than the metal content alone, which is why products with only a small metal component can be affected — the same rule described in the wall panel classification guide.

Two rules connect the layers. Goods covered by Section 232 are excluded from the 12.5% forced-labor duty, because the two do not stack. But since 232 duties apply to the full value, that exemption can be a poor trade: escaping 12.5% while paying 25% or more on the entire customs value can leave you worse off. Both directions have to be calculated. China Section 301 exclusions remain available, with 178 in force through 9 November 2026.

What Is Still Being Decided

Two live proceedings could add a new layer to Chinese goods:

• The Section 301 excess-capacity investigation, self-initiated in March 2026 against 16 economies including China, the EU, Vietnam and Mexico, covering the majority of US imports. No rate has been imposed yet; if action follows, it adds a layer rather than replacing anything.
• The second four-year review of the China Section 301 measures, opened in May 2026, which can adjust both rates and scope.

What This Means If You Are Importing

These changes are not an argument for waiting — they are an argument for knowing which line you are on before committing to a price. Everything here hangs off classification: the base rate, the Section 301 list, whether Section 232 reaches the product, and whether a 232 exemption costs more than it saves.

So the sensible questions to put to whoever handles your entries are: which HTSUS line is being used, and why; is my product inside any Section 232 scope, and if so is the duty on the full value; do I lose the 12.5% forced-labor duty by being inside Section 232, and is the total better or worse for it; which of my lines have exclusions, and when do they expire; and what changes on my next reorder date rather than today.

Anyone quoting a single percentage for “imports from China” is giving you an average, not your number: the mix of lines, the materials and the date of entry all move the total, which is why a breakdown beats a rate. Two categories have a live connection to these changes — solar and lighting products, where the December polysilicon measures land, and products that combine plastics, wood or metal, where classification decides more than freight does. The solar street light guide and the city and category guide show how those stacks are built, and the entry side is set out in US customs clearance for imports from China.

Frequently Asked Questions

Are IEEPA tariffs still being collected on Chinese goods?

No. The IEEPA tariff authority was struck down in February 2026 and the related orders were revoked that month. CBP has been refunding through its CAPE system since April, with a further phase for older liquidated entries on 6 October 2026.

What is the total tariff rate on Chinese goods in 2026?

There is no single rate. The total is the base rate of your HTSUS line, plus the Section 301 list duty for that line, plus the 12.5% forced-labor duty unless Section 232 covers the goods, plus Section 232 where it applies.

Do the 12.5% forced-labor duty and Section 232 stack?

No. Goods covered by Section 232 are excluded from the 12.5% forced-labor duty — though with 232 duties now on full customs value, both outcomes are still worth comparing.

What changes on 4 December 2026?

Polysilicon and its derivatives gain an additional 15% Section 232 duty and minimum import prices — $21 per kilogram for polysilicon, $100 per kilogram for ingots and wafers, $0.22 per watt for solar cells. Anti-stockpiling limits already apply.

Are the China Section 301 exclusions still available?

Yes. 178 exclusions are in force through 9 November 2026, and September’s amendments to four of them opened a correction route for entries made between 1 July and 22 September.